Henderson v. State
The Fourth DCA held that a sexual-assault-center nurse practitioner's testimony reading and summarizing clinical findings from a non-testifying examiner's report was inadmissible hearsay because she was acting as a mere conduit for the report rather than testifying from independent knowledge or general expert opinion. The court nonetheless affirmed Henderson's convictions for armed sexual battery, finding the error harmless beyond a reasonable doubt given the victim's own testimony, corroborating Williams-rule evidence, Henderson's partial confession, and strong DNA evidence.
Key facts
- Henderson was charged with armed sexual battery; a sexual-assault-center nurse practitioner testified at trial, reading and summarizing clinical findings from an examination report prepared by a non-testifying examiner.
- The trial court admitted the nurse practitioner's testimony about the contents of the absent examiner's report; Henderson was convicted of armed sexual battery.
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Why it matters
This opinion gives criminal practitioners a clear, citable application of the 'conduit witness' hearsay doctrine (Tolbert) to the common trial scenario of a substitute SANE nurse or medical witness testifying from… — full analysis with a trial
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